Specific tariff classification prevails for kitchen hoods with fans, while redemption fine may be reduced on the facts.

Imported kitchen hoods with a fan and filter arrangement were held to fall under heading 8414.60 as ventilating or recycling hoods incorporating a fan, because that specific tariff description prevailed over the broader claim of classification as an air purification system under heading 8421.39. Confiscation of the goods was sustained, but the redemption fine was reduced because the goods had earlier been cleared under S.I.L., leading to partial relief on penalty. The appeal succeeded only to that limited extent, while classification and confiscation were maintained.

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Issues: (i) Whether the imported goods were classifiable under heading 8414.60 as ventilating or recycling hoods incorporating a fan, or under heading 8421.39 as an air purification system; (ii) whether the confiscation and redemption fine required interference.

Issue (i): Whether the imported goods were classifiable under heading 8414.60 as ventilating or recycling hoods incorporating a fan, or under heading 8421.39 as an air purification system.

Analysis: The tariff description under heading 8414.60 specifically covered ventilating or recycling hoods incorporating a fan. On the nature of the imported goods, the device functioned as a kitchen hood with a fan and filter arrangement and answered that description more specifically than the claimed heading.

Conclusion: The goods were correctly classified under heading 8414.60 and not under heading 8421.39; this issue was decided against the appellant.

Issue (ii): Whether the confiscation and redemption fine required interference.

Analysis: Although confiscation was upheld, the goods had earlier been cleared under S.I.L., which justified reduction of the redemption fine.

Conclusion: The confiscation was sustained, but the redemption fine was reduced to Rs. 3 lakhs; this issue was partly in favour of the appellant.

Final Conclusion: The appeal succeeded only to the limited extent of reduction of redemption fine, while the classification and confiscation were maintained.

Ratio Decidendi: Where imported goods fall squarely within a specific tariff description, classification must follow that more specific entry, and redemption fine may be moderated on the facts even when confiscation is upheld.

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